Tagged: internal audit

Welcome! You Are the New Chief Compliance Officer: Five Basic Steps to Get Started

Congratulations on your new position as the chief compliance officer.  You successfully interviewed with the company, met the senior executive team and the audit committee chair, and negotiated a nice compensation package.  You are feeling “pretty, pretty good” (ala Larry David) about your new job and looking forward to starting your new position. So, now, what do you do? My first question for you is...

The Vital Role of Internal Audit to Compliance

A chief compliance officer can only succeed with the support of other important compliance partners.  Another way to put it – in the words of Blanche Dubois from A Streetcar Named Desire, “I have always depended on the kindness of strangers.”  This observation, while dramatic in license, applies to the place of the compliance officer in the corporate governance world. A key partner for compliance...

DOJ Compliance Expectations Concerning Training, Internal Investigations and Audits (Part IV of IV)

DOJ’s Compliance Evaluation questions provide important indications of “new” trends and approaches to compliance functions and issues. Training In the area of training, DOJ’s Compliance Evaluation reiterates DOJ’s concern that companies tailor their training programs to their specific risk profile. In the FCPA Guidance issued in 2012, DOJ explained that training programs should be tailored to specific audiences. DOJ has refined this requirement to focus...